Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
Rectification of mistake - Levy penalty u/s 271AAC or u/s 270 - No proceedings are pending before the CIT(A) - CIT (A) was not right in passing order of rectification by directing to initiate the penalty proceedings u/s 270A in place of penalty proceedings u/s 271AAC when admittedly vide her initial order dated 28.02.2022 has categorically held that addition made on account of alleged unaccounted sale u/s 68 is totally unjustified and consequently not covered u/s 115BBE of the Act and there was no income chargeable to tax under section 115BBE. - AT
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